We accept integrity, honesty, justice and respect for rights as fundamental principles in all our activities. In addition to complying with the laws of the countries in which we operate, we regard respect for people, the environment, society, traditions and customs as a requirement of our business culture. The Code of Business Ethics, which we have adopted as our core values, sets out the standards of behaviour for all our employees and stakeholders and guides our relationships to be conducted with integrity and honesty.

It is the primary responsibility of all employees to ensure that the name of Eralp and our group companies and the brands they own are recognised with trust, honesty and professionalism. In this regard, the expectations of our employees at Eralp and its group companies are listed below:

• To obey the law at all times,
• To fulfil their duties within the framework of basic moral and human values,
• To act with fairness, good faith and understanding in all relationships for mutual benefit,
• Not to obtain unfair gains from individuals and organisations for any purpose whatsoever, not to take or give bribes, to prevent such acts to the extent of their knowledge, to act in accordance with anti-corruption rules;
• To act in accordance with the relevant business ethics rules and all application principles supporting these rules in the duties carried out, and in this context, not to behave in a manner that prevents other employees from performing their work properly, not to disrupt business harmony
• Unless expressly authorised, not to engage in any behaviour, statement or correspondence that would put the company under commitment,
• To take care of all tangible and intangible assets of the company, including information and information systems, as if they were personal property, and to protect them against possible loss, damage, misuse, abuse, theft and sabotage,
• Not to use working time and company resources directly or indirectly for personal interest and/or political activity and benefit, with or without monetary value,
• Keeping wages, wage additions and arrangements to be made in time confidential, not sharing them with unauthorised persons and authorities inside and outside the organisation, not using them for speculative purposes in a way to disrupt the peace of work.

All company regulations, commitments and regulations on information security and confidentiality are accepted as complementary to the following articles.

• Ensure that legal proceedings are initiated and completed in a timely manner to secure intellectual property rights in newly developed products, processes and software and to prevent such inventions and information from being disclosed to third parties without written consent,
• to prevent the unauthorised use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies,
• In cases where confidential information relating to all types of intellectual and industrial property rights belonging to our company must be disclosed to third parties, to take the necessary measures to protect our rights in accordance with the relevant procedures.

• Ensure that all records are properly retained and archived within the legal retention period,

• Not to respond to requests from third parties for information that is considered confidential to the Company without the approval of senior management,
• Exercise due care to ensure that the Company’s statements and reports are truthful.

• To take the necessary measures to protect the company’s employees, information and information systems, business and administrative areas against possible terrorism, natural disasters and malicious attempts and to ensure communication,
• To carry out the necessary contingency planning in relation to the emergency crisis management to be established in the event of terrorism, natural disasters, etc., in order to ensure business continuity with minimum loss in the event of a crisis,
• To take all possible measures to prevent theft or damage to company assets.

• To act with the awareness that the financial and business secrets of Eralp and the Group companies, information that weakens the competitiveness of the companies, employee rights and information, agreements with business partners are within the scope of “confidentiality”, to ensure their protection and confidentiality,
• Not to disclose to unauthorised persons and authorities within and outside the organisation for any purpose whatsoever the information obtained as a result of business requirements and the documents in their possession, and not to use them (directly or indirectly) for speculative purposes,
• Not to use non-public information about the companies they work for, their customers and other people and companies with whom they do business for any purpose other than the intended purpose and not to disclose it to third parties without obtaining the necessary approvals.

• It is prohibited to share information about the Company on any platform, including social media channels, public forums, personal blogs, social media accounts, web and mobile applications that are not provided or controlled by the Company.

• Conflict of interest; it refers to any type of benefit provided to employees, their relatives, friends or persons or organisations with whom they have a relationship, and the situation in which they have a financial or personal interest related to them, which affects or may affect the ability of employees to perform their duties impartially.

• Not to take unfair advantage of himself, his relatives or third parties by using his title and authority,
• Ensure that personal investments do not create a conflict of interest with the current institution,
• To ensure that personal investments or activities other than any business activity do not interfere with the ongoing work of Eralp Chemicals and its group companies in terms of giving time and attention, and to avoid such situations that prevent concentration on the main duties.
• It is forbidden to be a superior if the employee and the person who is the main decision maker regarding the same job in the company, which is the customer or supplier, are relatives in the first degree.
• If it becomes known that relatives have shares or financial interests in another company with which they have business relations, it is mandatory to inform the superior.

Open to general participation by individuals or institutions with which we have or may have business relationships; conferences, receptions, promotional events, seminars, etc.; sporting activities, domestic/international travel, etc. that may influence or be perceived to influence decision making. Attendance at invitations is subject to the approval of the General Manager.

• Setting up a company on one’s own or becoming a partner in another company after leaving one’s job in the company and doing business with Eralp Chemicals and its group companies as a salesman, contractor, consultant or similar is a very important issue that should be taken into consideration as it may create a negative perception. It is also important to pay attention to the fact that an employee who leaves the company is in a senior management or decision-making position in another company.

• Before or after such a process, it is necessary to act within the framework of the company’s interests, to comply with moral and ethical rules and to avoid conflicts of interest before and after the process.

• In the case of re-employment of an employee who has left the company, it is a condition that his or her employment has not been terminated for non-compliance with any of the principles set out in the Code of Ethical Conduct and Implementation Principles.

• It is a criminal offence to attempt to gain any commercial advantage (insider trading), including directly or indirectly buying and selling shares on the stock exchange, by using or disclosing to third parties any confidential commercial, financial, technical, legal, etc. information belonging to Eralp and its group companies.

• To take the necessary measures to protect confidentiality even after leaving the company and to comply with the Information Security Commitment.

• Eralp and its group companies are against bribery and all forms of corruption. Corruption harms business life, institutions and their employees and causes irreparable damage to the company’s reputation and image. Eralp and its group companies are extremely careful and sensitive in the fight against bribery and corruption. All employees and third parties acting on behalf of the company are obliged to comply with anti-corruption rules and relevant legislation.

In principle, Eralp and its group companies prohibit all their employees from entering into relationships with any third party, including customers, suppliers, distributors, authorised dealers and authorised services, that may give the impression of obtaining a financial benefit, including offering and accepting gifts, invitations and entertainment.

The following criteria must be observed when dealing with private or public persons and organisations wishing to establish or maintain business relations with Eralp and its group companies;

• Any gift that gives the impression of impropriety, that may create or be perceived as creating a relationship of dependency (granting of a privilege or reference, winning of a tender, etc.), with the exception of materials given in accordance with legal and commercial customs and traditions or as souvenirs / promotional items, should not be accepted or offered.
• Gifts should never be given in cash or in a form that can be converted into cash (such as a gift certificate).
• Discounts or benefits that could be perceived as improper should not be requested from, offered to, and/or accepted if offered by suppliers, customers or third parties.

Eralp and its group companies do not tolerate any form of bribery or corruption. It strictly complies with the anti-bribery and corruption laws and regulations that apply wherever we do business and expects its employees to do the same.

• All payments to suppliers, consultants, etc. to other parties must be linked to the service/product and not to anything that could be construed as a bribe.
• Employees of Eralp and its group companies, as well as persons/institutions/organisations doing business on behalf of the company, must not offer, give or receive any gifts, gratuities, entertainment or other benefits that are believed to influence public or commercial decisions or cause improper performance of a public/commercial activity.
• All our employees have a duty to report any suspicion or allegation relating to any of the cases described in Article 2 (see Article 5 for guidance if you are unsure how to proceed).

• Our Group aims to ensure full health and safety in the workplace and at work. Employees shall act in accordance with the rules and instructions established for this purpose and shall take the necessary precautions. They accept the principle that activities to improve occupational health and safety are the joint responsibility of all employees,
• Employees will not keep in the workplace any items or substances that are hazardous to the workplace and/or employees, or that are illegal.
• Employees will not keep in the workplace any drugs, addictive substances or substances that impair or eliminate mental or physical faculties, except those kept on the basis of a valid medical certificate, and will not work in the workplace or within the scope of their work while under the influence of such substances.

Employees must avoid situations in which political activities may create a conflict of interest with their current duties and responsibilities.

• The company name, company title and company resources must not be used for personal political activities.
• Political propaganda may not be made during working hours or in the workplace environment, employees may not be asked to become members of a political party in any way, and the time of other employees may not be used for these activities.

Membership of non-governmental organisations and participation in their activities on behalf of the Company may be done with the knowledge of the Company.

Duty to report violations and concerns

Eralp and its group companies are committed to open and transparent communication. Our companies have an Ethics Line for employees to report transactions and behaviours that they believe violate Eralp Chemical’s policies and procedures. The Ethics Line can be contacted by e-mail (etik@eralpkimya.com / bilgi@eralpkimya.com).

In case of such concerns, employees are encouraged to first consult with their immediate supervisor without contacting the Ethics Line, but if their concerns are not resolved in this way, employees may contact the Ethics Committee, the authorised body of Eralp, through the Ethics Line.

Disclosure of the person’s report to third parties in a manner that could negatively affect workplace peace or business relations is strictly prohibited.

• It is not permitted to threaten, retaliate against or harm in any way, whether in or out of the workplace, an employee who refuses to act contrary to ethical rules and makes a report in good faith. Such behaviour will be interpreted as an ethical breach and the appropriate disciplinary action will be taken.
• It is very important that the person making the report is free from any intention, such as gossiping about the person reported or trying to negatively affect his or her career. In this regard, confidentiality, objectivity and compliance with ethical rules are extremely critical issues during the reporting and investigation process. It is imperative that those who both make the report and manage the process pay the utmost attention and care to this issue.
• If deliberate statements of a false and/or defamatory nature are detected, they will be interpreted as a violation of the ethical rules and the necessary disciplinary sanctions will be applied.

Management is primarily responsible for ensuring the appropriate environment and the effectiveness of the whistleblowing mechanism. Employees are sensitised to assist management in ensuring the effectiveness of the whistleblowing mechanism.

Some of the types of violations or inappropriate behaviour that can be reported include

• Environment, health and safety issues
• Workplace disputes and misconduct
• Situations involving breaches of privacy and data confidentiality
• Threats and physical violence
• Practices that violate internal and external laws
• Human rights and employee rights issues and/or suspected violations
• Criminal elements that may be considered bribery, corruption and security breaches
• Provision of unfair and personal benefits
• Disclosure of confidential information (within the scope of trade secrets, such as contracts, patents, project information, bid price information, undisclosed product prices and costs, company financial data and spreadsheets, customer and supplier information, personal employee information).
• Managers using employees for private business
• Being fair in performance appraisals
• Failure to treat employees equally
• Neglect and abuse of duty